Horizon Scanner Finance April 2026 - European Developments

ESG - Taxonomy delegated acts

The European Commission is seeking feedback on potential revisions to both of the following regulations:

• EU Taxonomy Climate Delegated Act: Which sets out technical screening criteria for climate mitigation and adaptation activities
• EU Taxonomy Environmental Delegated Act: Which covers the remaining four environmental objectives (sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems).

The consultations, which aim to update and simplify the technical screening criteria to make the taxonomy framework more user-friendly and accessible for market participants, will close for feedback on 14 April 2026 with adoption of a new simplified criteria expected later this year.

Consultations:

• Sustainable investment – review of the EU taxonomy climate delegated act
• Sustainable investment – review of the EU taxonomy environmental delegated act

Market Abuse Regulation (MAR)

ESMA’s Consultation proposing amendments to its MAR guidelines on the delay in the disclosure of inside information closes on 29 April 2026 (with a final report and final MAR guidelines expected in Q4 2026).

This Consultation follows the publication of the Listing Act in November 2024, which simplifies listing requirements to promote better access to public capital markets for EU companies, in particular SMEs by reducing the administrative burden on listed companies or companies seeking a listing. The Listing Act amended MAR by stipulating that, from June 2026, protracted processes will no longer be subject to the disclosure obligation until completion, and replaced the condition that a delay must not mislead the public with a requirement that the information the issuer intends to delay must not be in contrast with its latest public announcement on the same matter.

In response, ESMA is proposing to delete from the current MAR guidelines the legitimate interests for delayed disclosure connected to protracted processes, and is identifying additional legitimate interests for delay, such as where a public authority requests non-disclosure of inside information, the issuer needs to collect additional information, or where the issuer is participating in several procurement processes for similar contracts. As the Listing Act removed the condition that a delay in disclosure must not mislead the public from MAR, ESMA is also deleting the relevant section from its guidelines.

For background information, read our insights here:

Listing Act published in Official Journal: Update on changes to Prospectus and Market Abuse Regulations (debt securities)

EU Market Abuse Regulation: Listing Act changes relevant to debt capital markets

EMIR

As part of ESMA’s ongoing work to strengthen the EU’s post-trade infrastructure and derivatives market framework, ESMA has two consultations within the EMIR 3 reform package closing this month.

• Post-Trade Risk Reduction (PTRR) Consultation: ESMA’s PTRR Consultation, proposing draft Regulatory Technical Standards (RTS) on the requirements for PTRR services in connection with the new clearing obligation exemption introduced by EMIR 3, will close on 20 April 2026. The PTRR exemption entered into force with EMIR 3 on 24 December 2024 and exempts transactions resulting from PTRR services from the clearing obligation, subject to certain requirements. ESMA’s proposal in the consultation describes the requirements for the types of services eligible for the PTRR exemption; notably, compression, portfolio rebalancing and basis risk optimisation. It also sets out the framework for the PTTR service providers to operate in for the purposes of the exemption, including transparency towards participants, algorithm safeguards, execution of PTRR exercises, controls to be performed and record keeping.
• Central Counterparties (CCP) Collateral Consultation: ESMA’s CCP Collateral and Investment Policy Consultation addresses how CCPs manage financial resources – specifically what types of collateral (including guarantees) they can accept. EMSA is also proposing to make changes concerning (i) the conditions under which debt instruments can be considered as eligible financial instruments for the purpose of CCP investment policy and (ii) the types of highly secured arrangements in which emission allowances posted as margin or default fund contributions may be deposited. This consultation closes on 30 April 2026.

For both consultations, ESMA expects to publish its final reports and submit the final draft RTS to the European Commission for endorsement in Q4 2026.

Capital Requirements Directive (CRD IV) - Systemic risk buffer

The European Banking Authority’s (the EBA) Consultation on draft guidelines amending the guidelines on subsets of sectoral exposures for the systemic risk buffer closes on 30 April 2026.

The proposed amendments aim to update the existing guidelines to facilitate a more effective use of the systemic risk buffer to address systemic risks stemming from climate change. More specifically, the revised guidelines introduce greater granularity in identifying exposures subject to physical and transition risks related to climate change, through enhanced sectoral and geographical classifications.

The guidelines are expected to be finalised by mid-2026 and are envisaged to apply from six months after publication of the final guidelines.

EU banking market

As flagged last month, the European Commission’s call for evidence on the competitiveness of the single banking market closed for feedback on 11 March 2026. Its related consultation will close on 19 April 2026.

The consultation covers three main areas: banking competitiveness in the EU and globally; the single market and the banking union; and the complexity and effectiveness of the regulatory framework. Key themes running through the consultation include cross-border banking consolidation, global competition, regulatory stability and burden reduction, proportionality, and the incomplete state of the banking union, all of which are identified as significant challenges hindering the development of the single market for banking.

The Commission’s initiative in this area aims to examine the issues that may affect the competitiveness of the EU’s banking sector, assess their economic impact, and identify ways to address them. Responses will inform the Commission’s 2026 report on the competitiveness in the single banking market, which it expects to adopt in Q3 2026.

Consultation: Targeted consultation on the competitiveness of the EU banking sector 2026

Insurance – Solvency II and NatCat insurance

EIOPA’s Consultation on the assessment of the prudential treatment under Solvency II of adaptation measures in natural catastrophe (NatCat) insurance closes on 17 April 2026.

In Europe, there is a significant natural catastrophe insurance protection gap, with only around a quarter of losses from extreme events being insured. With climate change expected to increase the frequency and intensity of climate-related perils, adaptation measures, such as water-resistant floorings or reinforced walls for flood protection, can help reduce policyholders’ risk exposures and insured losses. At the same time, such measures can be key in maintaining the future supply of non-life insurance products covering climate-related hazards at affordable prices.

EIOPA has previously highlighted the key role that insurance undertakings can play in the adaptation of the society to climate change, by introducing the concept of “impact underwriting”. It encourages insurers to use their data, expertise, and risk assessment capabilities to incentivise policyholders to adopt adaptation measures. While progress in the sector can be seen, EIOPA notes that the EU insurance market is still in the early stages of integrating micro-adaptation measures into insurance products.

The objective of this Consultation is to assess if a dedicated treatment under Solvency II is justified to better reflect adaptation measures in the NatCat standard formula module beyond the regular calibration of its parameters.

Key areas of focus include:

• Risk sensitivity: Assessing if the current framework acts as an obstacle to "impact underwriting."
• Materiality: Evaluating the impact of adaptation measures from a Standard Formula perspective.
• Proportionality: Ensuring any new prudential treatments strike a balance between risk sensitivity and complexity.

Insurance

The European Insurance and Occupational Pensions Authority’s (EIOPA) Consultation on a draft supervisory statement on the authorisation and ongoing supervision of insurance and reinsurance undertakings owned by private equity firms closes on 30 April 2026.

Private equity (PE) backed insurers have grown significantly in recent years, particularly in the life insurance and annuity space. They often take an active role in defining the strategy of, and managing, the firms they acquire (the modus operandi). EIOPA notes that this can bring benefits but also pose challenges for supervisory authorities. Accordingly, the aim of the supervisory statement (which is non-binding but authoritative document setting out EIOPA's expectations of how national competent authorities (NCAs) should apply existing rules) is to ensure high-quality and convergent supervision of (re-)insurance undertakings related to PE firms, considering their specific nature and risks. It sets out supervisory expectations for acquisitions of qualifying holdings, portfolio transfers and mergers, as well as for on-going supervision.

The statement signals that EIOPA and NCAs will apply heightened scrutiny to PE-backed insurers and firms in this space should expect more enhanced ongoing supervision.

A final supervisory statement is expected to be published in late 2026, following consideration of consultation responses.